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February 27, 2023
Preventing Improper Payments: Lessons from Using Data
Matching in Pandemic Relief Program Oversight

For the past several decades, data matching has enabled the
use of government data to identify fraud, waste, abuse, and
mismanagement in benefit programs. Data matching is the
comparison of different datasets to identify similarities in
the records each dataset contains. Matches can be made
using one or more data elements, such as name, address,
email, bank account number, internet protocol address, or
Social Security number (SSN).
Oversight of federal funding for pandemic relief programs
is a recent demonstration of how data matching can be used
to detect improper payments. An improper payment is a
payment that should not have been made, either in its
entirety or in the wrong amount.
The Pandemic Response Accountability Committee
(PRAC) was established by the Coronavirus Aid, Relief,
and Economic Security (CARES) Act (P.L. 116-136) as
part of the Council of the Inspectors General on Integrity
and Efficiency (CIGIE). The PRAC is responsible for
providing transparency and oversight of pandemic
programs and expenditures. Since 2020, oversight agencies,
including the PRAC, have identified tens of billions of
dollars of COVID relief funding that may have been
compromised by potential fraud, waste, or abuse.
One way the PRAC has worked to detect improper
payments is through data matching using a data platform
it developed. The chair of the PRAC testified that this data
platform gives the PRAC access to more than 150 million
records to detect improper payments across a number of
pandemic relief programs.
This In Focus discusses the data platform established by the
PRAC, the risk of improper payments in pandemic
programs, and how, according to the PRAC and agency
inspectors general (IGs), data matching can be used to
prevent improper payments. There are several issues
Congress might consider on the use of data matching in
detecting and preventing improper payments.
Pandemic Anaiytics Center of Excellence
The PRAC has the statutory authority to conduct and
support oversight of all pandemic spending across
executive agencies. To support this role, the CARES Act
extended to the PRAC the authority given to IGs, including
to access agency records and request information to carry
out its responsibilities (134 Stat. 537; 5 U.S.C. App. §6).
In August 2021, the PRAC established the Pandemic
Analytics Center of Excellence (PACE), a data platform
managed by the PRAC's chief data officer in coordination
with the chief information officer. CIGIE has issued several

contracts to support PACE's technology and data
infrastructure and its various analytic capabilities.
PACE's operation broadly enables data sharing and data
analytics across IGs and law enforcement and assists in
investigations and audits of pandemic relief programs.
PACE is used to conduct data analysis, including data
matching and network analysis, and to develop data
services, including natural language processing and risk
modeling. PACE supports the investigative work of IGs and
the PRAC Fraud Task Force by uncovering potential fraud
and investigating leads.
For instance, PACE matched Economic Injury Disaster
Loan (EIDL) and Paycheck Protection Program (PPP) data
from the Small Business Administration (SBA) to create
fraud risk scores for both individuals and specific
applications. PACE has also developed a model for the
Department of the Treasury to score the risk associated with
79,000 prime and subrecipient awards to state and local
governments under the Coronavirus Relief Fund (CRF).
Treasury has used these scores to focus its reviews on
higher-risk CRF awards.
A Data Platform for Oversight Is Not New. PACE is
modeled after practices developed by the Recovery
Accountability and Transparency Board's Recovery
Operations Center (ROC), which supported oversight of the
American Recovery and Reinvestment Act of 2009 (P.L.
111-5). ROC demonstrated that the government could better
detect improper payments through data matching.
A report from the Government Accountability Office stated
that preservation of ROC's capabilities could help sustain
oversight of federal expenditures in general. Although
Congress authorized Treasury to take over ROC, it was
dissolved in 2015, effectively terminating the capacity and
expertise developed by ROC. While the PRAC is scheduled
to sunset in 2025, PACE could become a long-term data
platform for the IG community.
Risk of Improper Payments in Pandemic Programs
Congress provided over $5 trillion for the response to the
COVID-19 pandemic and its consequences. The amount of
funding appropriated, the scope and complexity of key
relief programs, and the focus on rapid disbursement of
funds to businesses and individuals all contributed to the
risk of improper payments for pandemic programs.
Another risk factor for improper payments in some
pandemic relief programs, such as the Pandemic
Unemployment Assistance (PUA) program, was the role of
states in their administration. According to the IG

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